Case Digest (G.R. No. 217453) Core Legal Reasoning Model
Facts:
Petitioner Denmark S. Valmores, a first-year student at the Mindanao State University–College of Medicine for Academic Year 2014–2015, is a devout member of the Seventh-day Adventist Church whose faith mandates strict observance of the Saturday Sabbath from sunset Friday to sunset Saturday. To prevent conflicts with his worship, Valmores wrote to Dean Dr. Cristina Achacoso requesting exemption from classes or exams moved to Saturdays, offering to make up any missed work. Between June and August 2014, several sessions—including a Histo-Pathology laboratory examination on September 13, 2014, under Professor Dr. Giovanni Cabildo—were rescheduled to Saturday, which he could not attend. Despite multiple letters and a certification dated September 15, 2014 from Pastor Hanani P. Nietes affirming his bona fide membership and need for exemption, no accommodation was afforded and he received a failing grade. Aggrieved, Valmores elevated the matter to the CHED Regional Office, Region X, w
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Case Digest (G.R. No. 217453) Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioner Denmark S. Valmores is a first-year student of Mindanao State University (MSU)–College of Medicine and a member of the Seventh-day Adventist Church, strictly observing the Saturday Sabbath from sunset Friday to sunset Saturday.
- Respondents Dr. Cristina Achacoso and Dr. Giovanni Cabildo are, respectively, Dean and faculty member of the MSU–College of Medicine.
- CHED Memorandum dated November 15, 2010 mandates that higher education institutions (HEIs) excuse students whose academic schedules conflict with their religious obligations and allow them remedial work without grade penalty.
- Chronology of Requests and Administrative Actions
- June–August 2014: Several classes and examinations for Academic Year 2014–2015 were rescheduled to Saturdays.
- September 13, 2014: Valmores missed his Histo-Pathology laboratory exam on Saturday, earned a failing grade, and was denied a make-up exam.
- September 2014: Valmores submitted letters to Respondent Achacoso and a church Certification (September 15, 2014) confirming his Sabbath observance; no accommodation was granted.
- Exhaustion of Internal and Regulatory Remedies
- January 6, 2015: CHED Regional Office indorsed the matter to MSU President and Dean Achacoso, recommending enforcement of the 2010 CHED Memorandum.
- MSU President instructed Dean Achacoso to comply; Respondent Achacoso still did not act.
- March 25, 2015: Valmores’s counsel wrote Achacoso, warning of legal action; no formal response ensued.
Issues:
- Procedural Issue
- Whether the Supreme Court may assume jurisdiction over a Rule 65 petition for mandamus directed at HEI officers despite the rule requiring filing in the Regional Trial Court.
- Whether other plain, speedy, and adequate remedies were exhausted before resorting to mandamus.
- Substantive Issue
- Whether respondents had a ministerial duty under the 2010 CHED Memorandum to excuse Valmores from Saturday classes and examinations upon submission of a proper church certification.
- Whether respondents’ refusal violated Valmores’s constitutional right to free exercise of religion.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)